Deposit Return Scheme. What you need to know.
Guidance for businesses in the hospitality sector that sell drinks in containers covered by Scotland’s Deposit Return Scheme.
Under the new Deposit Return Scheme (DRS), customers will pay a 20p deposit when purchasing a drink in a single-use container. They can then return the empty container to a return point and receive their deposit back. The scheme applies to single-use containers between 50 millilitres and 3 litres, made of PET plastic, aluminium, steel, or glass.
As a key part of Scotland’s future recycling system, the DRS is an example of extended producer responsibility (EPR). This means that drinks producers are responsible for the collection and recycling of the packaging their products come in.
Return point operators, including retailers and hospitality venues, will receive a handling fee to cover the costs of participating in the scheme. Online retailers will also be included to ensure accessibility for those who rely on online delivery.
Hospitality businesses such as restaurants, bars, cafes, and hotels will have different obligations depending on whether they sell drinks for on-site consumption or for customers to take away. If your business serves drinks in single-use containers for customers to consume off the premises, you will be required to charge a deposit and operate a return point. If customers only consume the drinks on-site, and you collect all the containers, you may choose not to charge a deposit and instead recover the 20p you pay your wholesaler or producer by getting the empty containers collected directly by the scheme administrator. You also don’t have to operate a public return point in this case.
Hospitality businesses that sell drinks containers to take away or be delivered can apply for an exemption consideration. Discussions are still ongoing on the full criteria to qualify for an exemption.
KEY DATES- Launching October 2025 at the earliest
To find out more about the DRS regulations and guidance on what the obligations might mean for your business, visit SEPA’s website. To apply for an exemption or to become a voluntary return point you can find out more here.
VAT Implications
The Scottish Government published a letter to HM Treasury in response to UK Government confirmation on how VAT will be applied to deposits issued under statutory Deposit Return Schemes (DRS).
As an annex to this letter, there is a fact sheet provided by HM Revenue & Customs which sets out how they envisage the VAT rules functioning. HM Revenue & Customs suggest businesses use this fact sheet as a guide to assist them in preparing for future legislative changes.
We encourage businesses to read the fact sheet and contact their VAT advisors or HMRC if necessary.